Giuffre_Maxwell_Batch2_p00315.png

Case 1:15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 7 of 20 documents. Moreover, Ms. Maxwell objects to this Interrogatory to the extent it calls for attorney work product and attorney client communications. The information sought is equally available to both parties within the public domain. Without waiver of the foregoing, Ms. Maxwell responds as follows: Ms. Maxwell is personally unaware of any particular coverage by any media regarding Mr. Gow’s communication to the British press. Any such articles or coverage of which she is aware have previously been produced in this action and are equally available to both parties in the public domain. 4. Identify all legal actions you, or someone acting on your behalf, have initiated, since January 1, 2015, identifying the jurisdiction, the date of initiation of the action, and the subject matter of the action. ANSWER: Ms. Maxwell objects to this Interrogatory as vague and ambiguous, specifically by failing to define “legal action.” Further, Ms. Maxwell objects to the extent the Interrogatory calls for attorney-client communications or attorney work product. Without waiver of the foregoing, Ms. Maxwell responds as follows: Ms. Maxwell has not filed any complaint in a court since January 1, 2015. 5. Identify all payments made or things of value transferred to you by Jeffrey Epstein, directly or indirectly or through any entity or person affiliated with or controlled by Epstein, from 1992 through the present, and if loans, detailing the amount of the loans, the terms of the loans, the interest rate of the loans, and any payments made by you or on your behalf to repay such loans. ANSWER: Ms. Maxwell objects to this Interrogatory on the grounds that it is overly broad and unduly burdensome and calls for information that is irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Ms. Maxwell objects to this Interrogatory on the grounds that it is propounded for the improper purpose of annoying or harassing Ms. Maxwell. Ms. Maxwell’s personal financial information is not at issue in this matter and information relating thereto is irrelevant. This Interrogatory also violates Local Rule 33.3(a) — (c) in that it does not seek the name of witnesses or the custodian and location of documents. Finally, Ms. Maxwell objects to this Interrogatory to the extent it seeks information from a time period not relevant to this action. Without waiver of the foregoing, Ms. Maxwell responds as follows: From the time period of January 1, 2015 through the present, Ms. Maxwell has had no payments made or things of value transferred to her, including loans, by Jeffrey Epstein or any entity or person affiliated with or controlled by him.